WHEN PRIME MINISTER TRUDEAU announced approval of the Trans Mountain pipeline expansion project, he linked that to Alberta’s goal of limiting emissions from oil sands production. “We could not have approved this project without the leadership of Premier Notley, and Alberta’s Climate Leadership Plan—a plan that commits to pricing carbon and capping oil sands emissions at 100 megatonnes per year,” Trudeau told Canadians.

The prime-ministerial logic here is challenging. Just ten days before, his Environment Minister Catherine McKenna had announced Canada’s emissions goal for 2050 would be 150 megatonnes—for the whole country. To accomplish that would require reducing national emissions by increments of 18 megatonnes every year from now until 2050. Yet Trudeau’s first action following McKenna’s announcement was to approve a project that would allow Canada’s annual emissions to grow by 18 megatonnes.

Even though they pull in opposite directions—one to higher emissions and the other to lower—Notley’s promise and McKenna’s goal amount to the same thing. They’re both paper-thin promises that can be broken at any time depending on who is governing Alberta and Canada. At the Trans Mountain announcement Trudeau said, “Climate change is real. It is here. And it cannot be wished or voted away.” On his assertion that climate change is real, a majority of British Columbians would probably agree. But both Trudeau and Notley can be voted away, and so can their legislation.

An expanded pipeline from Alberta to BC’s south coast, on the other hand, will create a permanent increase in risk to both the environment and southwest BC’s economy. Many Vancouverites and Victorians won’t let it happen without a fight—a physical one if it comes down to that.

But Trudeau’s linking of Trans Mountain with Notley’s pledge of “capping oil sands emissions at 100 megatonnes per year” creates a challenge for the prime minister. Where is the proof that limit hasn’t already been exceeded? If it can be shown that oil sands emissions are already over 100 megatonnes, would he rescind approval of the project? And on whom should the burden of proof fall?

Trudeau also said that Trans Mountain—by allowing oil sands production bound for export to grow substantially—would be good for Canada, economically. While that assertion might have been true in the economic paradigm in which continuous growth in fossil fuel emissions was assumed to be a sign of economic health, in the new paradigm in which Trudeau and McKenna hope to lead Canada— one where national emissions must shrink by another 18 megatonnes every year—does it make any sense at all?

Let’s start by examining the fundamental premise behind that “100-megatonne cap,” which is that it hasn’t already been exceeded.

WHERE DID JUSTIFICATION FOR a “100-megatonne” cap come from? Was the concept dreamed up by the Alberta Petroleum Marketing Commission? Consider why the number “100” might have been chosen. Who wouldn’t celebrate reaching 100? But is there any scientific evidence that supports that cap? None has been offered. Indeed, there are strong indications Alberta’s oil sands projects have long passed that symbolic mark.

Let’s begin with what Environment Canada claims. In 2014—the most recent year for which it has published figures (“Greenhouse Gas Emissions, April 2016”) describing oil sands-related emissions—they were put at 67.8 megatonnes. A “megatonne” is a million metric tonnes.

Environment Canada provides only three numbers in its inventory of greenhouse gas emissions to support that figure: one for “Oil sands—upgrading,” another for “Oil sands—in situ” and a third for “Oil sands—mining and extraction.” That’s it. That’s Environment Canada’s entire breakdown of emissions for an industry regularly described as the “fastest-growing source of emissions in Canada.” Again, those three numbers added up to 67.8 megatonnes in 2014.

The unavailability of information from the federal government around this highly controversial industry is startling. But because of the controversy—the oil sands have an international reputation as being a “dirty” source of energy—several independent analyses have been conducted to determine oil sands emissions intensity.

By “emissions intensity” we mean the amount of greenhouse gases released for each barrel of bitumen produced. Such analyses include carbon dioxide, methane, nitrous oxide and other GHGs.

The independent analyses—which have had varying levels of independence from the Alberta government and the oil sands industry—were conducted to compare the emissions intensity of fuels derived from oil sands bitumen with fuels refined from other sources of crude oil. Most of the studies divide the entire life cycle of a fuel into stages and assign an emissions intensity value to each stage. The stages include extraction, upgrading, transportation by pipeline to a refinery, refining, delivery from refineries to distribution terminals, and so on through to combustion. The emissions that Environment Canada attributes to the oil sands industry in Alberta are limited to those from extraction, upgrading and pipeline transportation. Very little of Alberta’s bitumen is refined in Canada, and refining emissions are inventoried by Environment Canada in a separate category.

So when Trudeau approved Trans Mountain because Alberta promised to cap “oil sands emissions,” it’s only those first three steps—extraction, upgrading and pipeline transportation—that are included.

The independent studies have arrived at different values for the overall carbon intensity of those first three steps. Using an average of those values, along with the oil sands production records of Alberta Energy Regulator and the National Energy Board, we can determine a reasonably good estimate of emissions attributable to those first three steps.

What stands out in doing that arithmetic is that only by using a value for emissions intensity from the very bottom of the range produced by the independent studies could a value of “67.8 megatonnes” be obtained for oil sands emissions in 2014.

In our effort to confirm Environment Canada’s oil sands emissions, we used the average values for “Canadian Oil Sands” “extraction” and “crude transportation” determined by a 2014 study conducted by the US Congressional Research Service (US CRS). That office describes itself as “providing policy and legal analysis to committees and Members of both the House and Senate, regardless of party affiliation.”

Its report was a meta analysis of six previous studies that determined emissions from the oil sands. The US CRS determined an average emissions intensity of about 20 grams of carbon-dioxide-equivalent for each megajoule of bitumen produced, including extraction, upgrading and pipeline transportation.

That works out to 122 kilograms of carbon-dioxide-equivalent emissions per barrel of bitumen produced. To cover the additional energy required for upgrading, we used a standard 10 kilograms of carbon-dioxide-equivalent emissions per barrel. When those numbers are applied to the oil sands’ 2015 production volumes recorded by Alberta Energy Regulator, emissions from Alberta’s oil sands operations grow to about 116 megatonnes. That suggests oil sands emissions could already be significantly higher than Notley’s 100 megatonne cap.

To obtain Environment Canada’s much lower, official level of emissions for the oil sands projects, carbon intensity values about one-half of that determined by US CRS would need to be used (11 grams of carbon dioxide for each megajoule of bitumen produced). A study done by the Jacobs Consultancy in 2012 placed oil sands production emissions in that range. (This study was not included in the US CSR’s analysis.) But that study’s authors noted, “Jacobs Consultancy has not made an analysis, verified, or rendered an independent judgment of the validity of the information provided by others.”

The Jacobs study was commissioned by the Alberta Petroleum Marketing Commission. That Alberta government organization’s mandate includes responsibility “for exploring new opportunities for building new markets for oil and gas products within North America and abroad, and improving access to current and new markets for oil sands products…” Do I need to point out that APMC are trying really hard to sell more bitumen?

A 2013 scientific study, “Historical trends in greenhouse gas emissions of the Alberta oil sands, (1970–2010)” by Jacob Englander et al, also provides data that challenges the Alberta/Environment Canada version of emissions. It considered data from each of the oil sands projects and put production emissions intensity at 20 to 22 grams of carbon dioxide equivalent for each megajoule of bitumen produced. It estimated emissions related to extraction, upgrading and pipeline transportation in 2010 were about “70 megatonnes.” Applying the large increase in daily production that has occurred since 2010 to Englander’s estimate, annual emission from the oil sands in 2015 would be approximately 117 megatonnes.

Additional scientific research published in 2015 by Sonia Yeh et al on the net emissions associated with land-use impacts resulting from oil sands production helps to illustrate the significant undercounting of emissions that is occurring. The authors note: “We found that land use and GHG disturbance of oil sands production, especially in-situ technology that will be the dominant technology of choice for future oil sands development, are greater than previously reported.”

Based on expected production levels out to 2030, the authors estimated emissions as high as 10 megatonnes per year just from land use impacts. The 2013 Englander study put land-use impact for in-situ production at zero, so even its finding of emissions intensity is likely an undercount of actual emissions (Englander contributed to the Yeh study). Yet Englander’s value for emissions intensity translates to overall oil sands emissions being nearly twice as high as Environment Canada admits.

The current scientific evidence and level of uncertainty, then, conflict with information created by industry and government marketing organizations. Yet that clash is invisible in Notley’s vaunted Climate Leadership Plan. In the 97-page “Report to Minister” that launched the plan, feel-good aspirations about possible reductions in oil sands emissions intensity abound, but there isn’t a single direct account of current oil sands emissions. There is an indirect reference—in a pie chart—that, if a reader does the arithmetic, suggests emissions might have been 58 megatonnes in 2013. But the avoidance of a rigorous accounting of current oil sands emissions in Notley’s plan is a flashing yellow light: What are current emissions and what does that include?

Focus requested a detailed inventory of all greenhouse gas emissions from Alberta’s Climate Change Office. The only data it could provide was collected under Alberta’s Greenhouse Gas Emissions Reporting Program. That information covered only half of Alberta’s acknowledged overall emissions and was limited to “facilities” that emitted 50,000 tonnes or more each year. The most recent report that’s available covers 2013 and doesn’t reflect significant increases in oil sands production since then. It put 2013 emissions at 58 megatonnes, just like the pie chart in Notley’s Climate Leadership Plan.

Since 2013, Alberta oil sands production has increased by about 629,000 barrels per day. That increase alone, at the US Congressional Research Service’s carbon intensity average of 20 grams of carbon-dioxide-equivalent for each megajoule of bitumen produced, would have added close to 30 megatonnes. Added to Environment Canada’s dubious 2013 account of oil sands emissions, Alberta would now be at 94 megatonnes.

Let me sow a little more doubt about Environment Canada’s account of emissions. In the same publication as it provides its brief three-number summary of oil sands emissions mentioned earlier, it also summarizes “fugitive emissions” for all of Canada’s oil and gas industry, including the oil sands. Fugitive emissions are the greenhouse gases that escape from tailings ponds, oil sands mine faces, oil and gas valves, pumps and pipelines, and so on.

Environment Canada claims 30.5 megatonnes of oil- and gas-related fugitive emissions for 2012 (see its Table A.4. above). Yet provincial breakdowns of emissions data from Canada's National Inventory Report of emissions filed with the UN for 2012 show that fugitive emission produced by the oil and gas industry were actually 61 megatonnes. In other words, there’s 30 megatonnes of fugitive emissions from Canada’s oil and gas industry that are missing from Environment Canada’s description of the industry’s emissions. The lion’s share of oil and gas fugitive emissions, by the way, are released by Alberta—35 megatonnes each year.

That missing 30 megatonnes largely makes up the difference between the public perception of where oil sands emissions are currently (68 megatonnes) and Notley’s Cap (100 megatonnes).

When questioned by Focus, Environment Canada was unable to explain why fugitive emissions from the oil and gas industry were not fully counted in its depiction of national oil and gas sector emissions. It noted that the missing emissions were included in Canada’s National Inventory Report as submitted to the UN.

Trudeau and McKenna know that Canada’s emissions reporting procedures need to be improved and have proposed legislation to accomplish that. Under Stephen Harper’s climate-change-skeptical government, the reporting threshold for an industrial emitter had been 100,000 tonnes per year but was lowered to 50,000 tonnes in 2010. Now Environment Canada is hoping to move that down to 10,000 tonnes.

But on the day Trudeau approved Trans Mountain, he expressed certainty that the facts and figures were on his side. “This is a decision based on rigorous debate, on science and on evidence,” Trudeau said. “We have not been and will not be swayed by political arguments—be they local, regional or national.”

Prime Minister Trudeau linked approval of Trans Mountain to oil sands emissions not exceeding 100 megatonnes. But the best analysis that’s been applied to measurement of those emissions suggests it could already be as high as 120 megatonnes. That’s not a political argument. It’s a serious question about the “evidence” Trudeau is using.

NOTLEY'S CAP, the promise to somehow hold oil sands emissions to no more than 100 megatonnes, presumes they’re currently either 58 (Alberta) or 68 (Environment Canada) megatonnes. Through the cap, Alberta is giving itself permission to ramp up oil sands production by about 50 percent above current levels. The Canadian Association of Petroleum Producers’ 2016 projection to 2030 show oil sands production climbing to around 3.5 million barrels a day by about 2028 and then beginning to accelerate.

At the same time, the Trudeau government is acting on its commitment to significantly reduce Canadian emissions by imposing an escalating price on carbon for any province that doesn’t follow its lead.

The contradiction of facilitating oil sands growth while discouraging the use of fossil fuels with a carbon tax or fees is jarring enough. But the bizarre, long-term consequences for the Canadian economy of these two initiatives, if they both play out as hoped for by Trudeau and Notley, seems to have been overlooked.

As national emissions decline, emissions caused by production of bitumen destined for export will come to dominate Canada’s carbon budget. If Alberta’s fossil-fuel exports have a stranglehold on allowable emissions, its oil and gas industry could choke off economic opportunity in the rest of Canada.

Oil and gas extraction have high emissions per dollar of economic value that they create. Other industries in the same boat, like electricity and heat utilities, construction, manufacturing, forestry and agriculture, will be required to pay the same level of carbon fees for their activities even though their products—electricity, heat, infrastructure, housing and food—are essential to the well being of Canadians. Are exports of fossil fuels to the US necessary for Canadians to have a good quality of life? Where is the proof of that?

How soon might the strangling of the Canadian economy begin? For the analysis below, we start with Environment Canada’s numbers.

Environment Canada reports that, in 2014, 192 megatonnes of emissions were attributable to the oil sands and conventional oil and gas industries. As noted earlier, however, Environment Canada had removed 30 megatonnes of fugitive emissions from that account. If we put them back in, emissions related to Canada’s oil and gas industries were 222 megatonnes. How much of that was attributable to exported fossil fuels?

That year, according to the National Energy Board, 77.5 percent of crude oil and 47.5 percent of natural gas was exported. If those percentages are applied to the appropriate components of Environment Canada’s 222 megatonnes, emissions related to net exports of natural gas and oil, including bitumen, total 146 megatonnes.

So, two years ago, using Environment Canada’s suspect numbers, just emissions resulting from production of fossil fuels destined for export were already pushing McKenna’s mid-century goal of 150 megatonnes for Canada’s entire emissions budget.

If oil sands production continues to grow at the rate projected by Alberta Energy Regulator, then emissions from producing fossil fuels for export will climb at about the same rate. You might ask: Won’t there be improvements in emissions intensity?

The previously-mentioned study by Englander et al indicates the industry has flat-lined on improvements in emissions intensity since about 2005 and the increase in the extent of in-situ extraction, which is more emissions intensive than surface mining, could cancel out any efficiency gains that might be possible through improvements in technology. In-situ extraction involves injecting steam into the ground deep below the surface and, in effect, melting the bitumen out of the sands that contain it. It’s a process that involves burning a lot of natural gas to heat up water for steam. That form of extraction is expected to account for 60 percent of all bitumen production by 2025.

By 2035, emissions from production of fossil fuels destined for export could eat up more than 50 percent of all allowable emissions as Canada reduces its national emissions towards McKenna’s goal of 150 megatonnes. By 2045, producing fossil fuels for export could consume all of Canada’s allowable emissions.

If oil sands emissions have been underestimated to the extent suggested by the US CRS emissions intensity finding and other studies, emissions related to fossil-fuel exports could consume half of Canada’s carbon budget by 2028—and all of it by 2040.

Not included in this analysis is the potential for a large increase in emissions that would result from an increase in export of natural gas from Alberta, not covered by Notley’s Cap. The province’s vast and largely untapped reservoir of shale gas—estimated by Alberta to be 110 times larger than its conventional gas reserve—could come under intense development pressure if natural gas production in the US begins to falter.

The inevitable consequence of allowing oil sands production to grow—rather than starting to cut it back now—will be that Canada’s allowable emissions will be dominated by production of low-value bitumen for export, mainly to the US. Canada would never be able to turn off our powerful neighbour’s supply. Our country’s economic role in the world would then be to serve as America’s pump jockey.

When Trudeau announced approval of Trans Mountain he told his audience: “I have said many times that there isn’t a country in the world that would find billions of barrels of oil and leave it in the ground while there is a market for it.” The prime minister is apparently stuck on that idea and is unable to see that it no longer fits with the more fundamental need to lower carbon emissions and prepare properly for the low-carbon economy that Canada needs to build. Meanwhile, as Alberta’s premier flails about in a sea of low-value hydrocarbons, her promises threaten to pull the rest of Canada under with her. Trudeau has thrown her a life-ring, but to what end?